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July 17, 2015

Dear Sir or Madam,

Brasfield & Gorrie, L.L.C., hereby submits to the Federal Aviation Administration, pursuant to the FAA 

Modernization and Reform Act of 2012, an exemption petition, in accordance with section 333 of the 

Act.

Brasfield & Gorrie, L.L.C. Background

Recently celebrating our 50th anniversary, Brasfield & Gorrie has marked 2015 as the year we achieved 

our goal of obtaining the ranking of Best General Contractor as announced by the Associated Builders 

and Contractors. Brasfield & Gorrie is one of the largest privately held construction firms in the nation. 

Our mission is strengthening relationships by honoring commitments, exceeding expectations, and living 

our values every day. Brasfield & Gorrie owes its success to its people. The company founders 

established a reputation for unwavering quality and integrity, and those values remain the bedrock of 

our business philosophy today. Because safety is our top priority, it is also our top corporate value. We 

strive to be the safest general contractor in every market we serve, and we are committed to ensuring 

the safety of our employees, clients, and associates. Our “THINK Zero!” safety initiative reflects our goal 

of zero incidents on all our projects. Our company website, BrasfieldGorrie.com, houses a wealth of 

information pertaining to the scope of work we conduct.

Purpose for the Exemption

Brasfield & Gorrie is interested in utilizing an unmanned aircraft system (UAS) to conduct surveys, 

inspections, and photography of our jobsites and client facilities.

Point of Contact Information

Timothy Eichelberger

Chief Pilot 

Brasfield & Gorrie

3021 7th Ave South

Birmingham, AL 35233

Mobile (205) 249-9706

Office (2050 714-1842

Email: TEichelberger@brasfieldgorrie.com
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TERMS OF REFERENCE: 

1. Aircraft: any contrivance invented, used, or designed to navigate, or fly in, the air (Title 49, United 

States Code (49 USC) § 40102)

2. National Airspace System (NAS): the common network of U.S. airspace; air navigation facilities, 

equipment and services, airports or landing areas; aeronautical charts, information and services; rules, 

regulations and procedures, technical information, and manpower and material 

3. Operational Control: with respect to a flight, means the exercise of authority over initiating, 

conducting or terminating a flight (14 CFR § 1.1)

4. Pilot in Command (PIC): the person who has final authority and responsibility for the operation and 

safety of the flight; has been designated as PIC before or during the flight; and holds the appropriate 

category class and type-rating, if appropriate, for the conduct of the flight (14 CFR § 1.1)

5. Unmanned aircraft (UA): any aircraft that is operated without the possibility of direct human 

intervention from within or on the aircraft (P.L. 112-95, Section 331) 

6. Unmanned Aircraft System (UAS): an unmanned aircraft and associated elements, including 

communication links and the components that control the unmanned aircraft, that are required for the 

pilot in command to operate safely and efficiently in the national airspace system (P.L. 112-95, Section 

331) 

7. UAS Certificate of Waiver or Authorization (COA): an authorization issued by the Air Traffic 

Organization to an operator for a specific unmanned aircraft activity

8. Visual Line of Sight (VLOS): unaided (corrective lenses and/or sunglasses excepted) visual contact 

between a pilot in command and an unmanned aircraft sufficient to maintain safe operational control of 

the aircraft, know its location, and be able to scan the airspace in which it is operating to see and avoid 

other air traffic or objects aloft or on the ground
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List of Specific Sections of 14 CFR for which exemption is sought: 

Petitioner: Brasfield & Gorrie L.L.C.

-61.23(a) and (c)

-61.113(a)

-91.7(a)

-91.103(b)(2)

-91.105

-91.109

-91.119(c)

-91.121

-91.151(a)(1)

-91.405(a)

-91.407(a)(1)

-91.409(a)(1) and (2)

-91.417(a) and (b)
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Expanded 14 CFR sections exemption is requested and why:

§61.23(a) and (c) Medical certificates: Requirement and duration.

(a) Operations requiring a medical certificate. Except as provided in paragraphs (b) and (c) of this section, a person—

(1) Must hold a first-class medical certificate:

(i) When exercising the pilot-in-command privileges of an airline transport pilot certificate;

(ii) When exercising the second-in-command privileges of an airline transport pilot certificate in a flag or supplemental 

operation in part 121 of this chapter that requires three or more pilots; or

(iii) When serving as a required pilot flightcrew member in an operation conducted under part 121 of this chapter if the pilot 

has reached his or her 60th birthday.

(2) Must hold at least a second class medical certificate when exercising:

(i) Second-in-command privileges of an airline transport pilot certificate in part 121 of this chapter (other than operations 

specified in paragraph (a)(1)(ii) of this section); or

(ii) Privileges of a commercial pilot certificate; or

(3) Must hold at least a third-class medical certificate—

(i) When exercising the privileges of a private pilot certificate; 

(ii) When exercising the privileges of a recreational pilot certificate; 

(iii) When exercising the privileges of a student pilot certificate;

(iv) When exercising the privileges of a flight instructor certificate and acting as the pilot in command;

(v) When exercising the privileges of a flight instructor certificate and serving as a required pilot flight crewmember;

(vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, commercial pilot, or airline transport pilot 

certificate, or for a flight instructor certificate; or

(vii) When performing the duties as an Examiner in an aircraft when administering a practical test or proficiency check for an 

airman certificate, rating, or authorization.

(c) Operations requiring either a medical certificate or U.S. driver's license. (1) A person must hold and possess either a 

medical certificate issued under part 67 of this chapter or a U.S. driver's license when—

(i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in a light-sport aircraft other than a 

glider or balloon;

(ii) Exercising the privileges of a sport pilot certificate in a light-sport aircraft other than a glider or balloon;

(iii) Exercising the privileges of a flight instructor certificate with a sport pilot rating while acting as pilot in command or serving 

as a required flight crewmember of a light-sport aircraft other than a glider or balloon; or

(iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot certificate in a light-sport 

aircraft other than a glider or balloon.

(2) A person using a U.S. driver's license to meet the requirements of this paragraph must—

(i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and any judicial or administrative

order applying to the operation of a motor vehicle;

(ii) Have been found eligible for the issuance of at least a third-class airman medical certificate at the time of his or her most 

recent application (if the person has applied for a medical certificate);

(iii) Not have had his or her most recently issued medical certificate (if the person has held a medical certificate) suspended 

or revoked or most recent Authorization for a Special Issuance of a Medical Certificate withdrawn; and

(iv) Not know or have reason to know of any medical condition that would make that person unable to operate a light-sport 

aircraft in a safe manner.

Brasfield & Gorrie requests exemption based on:

-Medical requirements do not, currently, provide guidance for the operator (PIC) of UAS. However, PIC 

of Brasfield & Gorrie operated UAS will have at least current third class medical certification.

Level of safety retained:

PIC will be required to have a current third class medical to operate the UAS which aligns with the 

private pilot requirements.
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§61.113 Private pilot privileges and limitations: Pilot in command.

(a) Except as provided in paragraphs (b) through (h) of this section, no person who holds a private 

pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property 

for compensation or hire; nor may that person, for compensation or hire, act as pilot in 

command of an aircraft. 

Brasfield & Gorrie requests exemption based on:

-The UAS Brasfield & Gorrie intends to operate is the DJI Inspire. It weighs less than 6.5 lbs., cannot 

exceed 50 mph of forward flight, cannot carry cargo or passengers, and is limited to 13 min flight time. 

In addition to these parameters, the airspace in which the DJI Inspire will operate will be that which 

does not interfere with other air traffic. However, the PIC will have full authority and responsibility 

towards the safe operation of the UAS missions. The PIC will have logged training flights that include 

emergency, evasive, and high wind procedures to ensure mission safety. 

Level of safety retained:

A private pilot is trained extensively on visual flight rules which are the whole environment in which the 

UAS will operate. Besides UAS operation, no additional training would be required to achieve the safety 

and preflight planning that a higher certificate would enable, such as a commercial or airline transport 

certificate. 
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§91.7 Civil aircraft airworthiness.

(a) No person may operate a civil aircraft unless it is in an airworthy condition. 

Brasfield & Gorrie requests exemption based on:

-While no airworthiness certification exists for the DJI inspire, the UAS is flight tested prior to release to 

the public as well as all FCC considerations and regulations met. PIC preflight action prior to each flight

will be mandatory to ensure safe operation is possible. Manufacturer guidelines as well as Day VFR 

flight rules and other atmospheric condition requirements will provide go/no-go decision making 

information. By limiting our operation to this equipment, we feel retains the intent of the testing and 

validation that an airworthiness certificate provides.

Level of safety retained:

The DJI Inspire is a mass produced, heavily tested product that has position, control, and communication 

redundancy. The flight path will not be over persons on the ground. The UAS would be the same unit 

that the PIC and VO train on in various scenarios so flight characteristics would be a known quantity 

before actual missions take place.
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§91.103 Preflight action.

Each pilot in command shall, before beginning a flight, become familiar with all available information 

concerning that flight. This information must include—

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing 

distance information: 

(2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable 

information appropriate to the aircraft, relating to aircraft performance under expected values of airport 

elevation and runway slope, aircraft gross weight, and wind and temperature. 

Brasfield & Gorrie requests exemption based on:

-While Brasfield & Gorrie UAS operations will absolutely include extensive preflights prior to flight, items 

listed in this regulation such as “runway slope”, “airport of intended use”, and “aircraft gross weight” do 

not have direct applicability. 

Level of safety retained:

Preflight action to retain the level of safety intended by this regulation will include site analysis as it 

relates to the predetermined flight path. Jobsite leadership will be contacted to plan the UAS flight path 

as well as emergency and escape routes. The UAS will be inspected prior to flight in accordance with the 

manufacturer’s recommended procedure. VFR weather minimums will be considered prior to flight and 

a no go decision will be made if assurance of cloud and visibility clearance restrictions are not possible. 
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§91.105 Flight crewmembers at stations.

(a) During takeoff and landing, and while en route, each required flight crewmember shall—

(1) Be at the crewmember station unless the absence is necessary to perform duties in connection with 

the operation of the aircraft or in connection with physiological needs; and 

(2) Keep the safety belt fastened while at the crewmember station. 

(b) Each required flight crewmember of a U.S.-registered civil aircraft shall, during takeoff and landing, 

keep his or her shoulder harness fastened while at his or her assigned duty station. This paragraph does 

not apply if—

(1) The seat at the crewmember's station is not equipped with a shoulder harness; or 

(2) The crewmember would be unable to perform required duties with the shoulder harness fastened. 

Brasfield & Gorrie requests exemption based on:

-The DJI Inspire 1, which Brasfield & Gorrie intends to operate has a total weight of less than 6 lbs. and is 

incapable of carrying any crew members onboard. Flight Crew, as it relates to this regulation, will 

consist of a Pilot in Command (PIC) and a Visual Observer (VO).

Level of safety retained:

It is the intent of this regulation to ensure that flight crew members are in a position to immediately 

conduct emergency procedures and maintain constant positive control of the aircraft. With the flight 

crew of the UAS consisting of a PIC and VO, the PIC will be able to maintain constant positive control of 

the UAS with verbal cues from the VO as well as the VO being able to assure obstruction and person 

clearance as well as constant escape route planning during each phase of flight.
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§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully 

functioning dual controls. However, instrument flight instruction may be given in an airplane that is equipped with a single, functioning 

throwover control wheel that controls the elevator and ailerons, in place of fixed, dual controls, when—

(1) The instructor has determined that the flight can be conducted safely; and 

(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. 

(b) An airplane equipped with a single, functioning throwover control wheel that controls the elevator and ailerons, in place of fixed, dual 

controls may be used for flight instruction to conduct a flight review required by §61.56 of this chapter, or to obtain recent flight experience or 

an instrument proficiency check required by §61.57 when—

(1) The airplane is equipped with operable rudder pedals at both pilot stations;

(2) The pilot manipulating the controls is qualified to serve and serves as pilot in command during the entire flight;

(3) The instructor is current and qualified to serve as pilot in command of the airplane, meets the requirements of §61.195(b), and has logged at 

least 25 hours of pilot-in-command flight time in the make and model of airplane; and

(4) The pilot in command and the instructor have determined the flight can be conducted safely.

(c) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings 

appropriate to the aircraft being flown. 

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements 

the vision of the safety pilot; and 

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument 

flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls 

of the elevator and ailerons, when—

(i) The safety pilot has determined that the flight can be conducted safely; and 

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings. 

(d) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on 

that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully 

qualified to act as pilot in command of the aircraft. 

Brasfield & Gorrie requests exemption based on:

-Brasfield & Gorrie intends to conduct in-house UAS operations training with the aid of qualified and 

experienced single and multirotor UAS operators. These instructors will be at least of private pilot 

certification and have experience either in a commercial or hobby use setting. Brasfield & Gorrie will 

develop a training curriculum which includes normal operations as well as emergency and evasive 

operations. While Brasfield & Gorrie will refer to these individuals as “instructors”, they will be unable 

to meet the criteria listed in this regulation due to certification not existing as well as aircraft 

requirements not being able to be met. 

Level of safety retained:

When possible, an FAA certified flight instructor will be used to instruct new UAS operators to maintain 

FAA initiatives in flight training, such as scenario based training. With each student operator being at 

least a private pilot, foundational preflight actions, weather knowledge, and good aeronautical decision 

making will be built upon in training the individual for UAS operation.
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§91.119 Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following 

altitudes: 

(b) Over other than congested areas. An altitude of 500 feet above the surface, except over open 

water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 

500 feet to any person, vessel, vehicle, or structure.

Brasfield & Gorrie requests exemption based on:

-The mission of the UAS as it applies to Brasfield & Gorrie operations will require lower altitude. 

Currently, UAS operations allowed and regulated by the federal allow for a 400’ AGL ceiling which will 

better insulate the UAS from any unforeseen air traffic.

Level of safety retained:

A 400’ ceiling will help to insulate the different types of aircraft. Also, having a VO will enable the PIC of 

the UAS to see and avoid any aircraft that penetrate that boundary unkowningly
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§91.121 Altimeter settings.

(a) Each person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, 

as the case may be, by reference to an altimeter that is set, when operating—

(1) Below 18,000 feet MSL, to—

(i) The current reported altimeter setting of a station along the route and within 100 nautical miles of 

the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current 

reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or an 

appropriate altimeter setting available before departure; or 

(2) At or above 18,000 feet MSL, to 29.92′′ Hg. 

Brasfield & Gorrie requests exemption based on:

-The DJI Inspire is able to calculate, sense, and derive altitude information via onboard GPS, Barometer 

and Vision Positioning System. The Barometer can be set at zero prior to flight to ensure a max ceiling 

of 400’ AGL is able to be complied with. Also the GPS can give accurate indications of altitude. This 

information is displayed on the Ground Control Station.

-Max operations altitude (400’) is often under Minimum safe altitude as described in regulation. 

However, the UAS will not be operated as to provide a danger to persons or property. Operations will 

be limited to current Brasfield & Gorrie jobsites and/or owned property and structures. Flight will never 

be routed over employees or the general public as we are able to control. Mission planning will be 

coordinated with jobsite leadership to ensure flight path while maintaining safety. 

Level of safety retained:

Since the UAS operations will be limited to line of sight, the ability to continuously adjust for changing 

barometric pressure is not required. However, being able to derive UAS absolute altitude via three 

possible sources will assure an altitude below 400’ AGL. Also a safeguard 400’ AGL limit may be 

programmed prior to flight to ensure the UAS flight does not take place above the altitude limit.
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§91.151 Fuel requirements for flight in VFR conditions.

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and 

forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming 

normal cruising speed—

(1) During the day, to fly after that for at least 30 minutes 

Brasfield & Gorrie requests exemption based on:

-Batteries will be maintained and operated per manufacturer recommendations. Most flight stage 

length will take place under the minimum requirement for VFR fuel reserves. Battery capacity and 

charge level will be monitored during the flights and flight will be safely discontinued at any point that a 

battery comes within the maximum depletion level.

Level of safety retained:

The DJI Inspire 1 has safeguards in place to both warn the PIC and auto land in the event of battery 

starvation. These safeguards and that fact that neither cargo nor passengers will be carried assure the 

level of safety that 14 CFR 91.151 desires.
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§91.405 Maintenance required.

Each owner or operator of an aircraft—

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as 

prescribed in part 43 of this chapter;

Brasfield & Gorrie requests exemption based on:

-UAS will be maintained per manufacturer recommended procedures and repair stations as needed.

Level of safety retained:

Preflight action will serve as a continuous maintenance program in addition to manufacturers 

recommended procedures. If at any point a component is found to be worn or broken beyond repair, 

that part will be replaced with the manufacturers recommended replacement part and the work shall be 

done either by the manufacturer when able or a knowledgeable repair facility.
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§91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, 

rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; 

and 

Brasfield & Gorrie requests exemption based on:

-Return to service test flights will be conducted by a fully trained operator as recommended by the 

manufacturer.

Level of safety retained:

Return to service flights will be conducted in a controlled area, away from obstacles, persons, or 

property. An extensive preflight will be conducted; focusing on the repaired component and 

subsequent flight testing of all phases of flight will be conducted and logged prior to returning the UAS 

to service.
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§91.409 Inspections.

(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, 

within the preceding 12 calendar months, it has had—

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by §43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this 

chapter.

No inspection performed under paragraph (b) of this section may be substituted for any inspection 

required by this paragraph unless it is performed by a person authorized to perform annual inspections 

and is entered as an “annual” inspection in the required maintenance records. 

Brasfield & Gorrie requests exemption based on:

-Preflight and system monitoring will be in accordance with manufacturer’s recommendations which do 

not comply with standard aircraft inspection requirements. However, if at any point a system is found 

to be defective or no longer operational, it will be removed and/or replaced with an operational 

replacement part. All maintenance records will be logged and available to the PIC prior to each flight.

Level of safety retained:

Repairs and inspections will be conducted by the manufacturer or a knowledgeable repair facility in 

order to ensure proper repairs in accordance to manufacturer recommendations.
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§91.417 Maintenance records.

(a) Except for work performed in accordance with §§91.411 and 91.413, each registered owner or 

operator shall keep the following records for the periods specified in paragraph (b) of this section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft 

(including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must 

include—

(i) A description (or reference to data acceptable to the Administrator) of the work performed; and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 

(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance.

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection required 

by the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for 

each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety 

directive involves recurring action, the time and date when the next action is required.

(vi) Copies of the forms prescribed by §43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances.

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with 

the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under §43.11 of this chapter shall be 

retained until the defects are repaired and the aircraft is approved for return to service. 

Brasfield & Gorrie requests exemption based on:

-All Maintenance records will be logged and be in accordance with manufacturer’s recommendations.

These records will be available to the PIC prior to each flight.

Level of safety retained:

Each UAS that Brasfield & Gorrie operate will have an accompanying maintenance log sheet that shows 

date, place, and nature of repair. Each UAS will also have a flight log reflecting flight notes, return to 

service flights, and any abnormalities noted by the PIC.
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Unmanned Aircraft Description

-The UAS used will be the DJI Inspire. The Inspire is a Quadcopter design, capable of capturing 4k Video 

and transmitting to multiple devices. While the Inspire is controlled by a remote control, positioning is 

assured and stored by the use of GPS. In addition to GPS position confirmation, Vision Positioning 

technology provides hovering precision when no GPS signal exists. The Inspire is preprogrammed with 

fail safe features that add to the safety of operation. A Return To Home system is activated with a 

manual button, and automatically with a low battery indication or loss of communication with the 

transmitter. Vertical and Lateral boundaries may be established prior to each flight to ensure reception, 

and operations area containment and safety. 

Following the petition summary are documents provided by the manufacturer:

A. -Inspire 1 User Manual

B. -Inspire 1 Safety Guidelines

C. -Inspire 1 Maintenance Manual

Radio Frequency Information

-Both controllers that come with the Inspire are listed by the manufacturer to be CE and FCC compliant. 

Controller and video link transmission operate at 2.4GHz and have a maximum range of 2 kilometers. 

PIC Qualifications

-Each pilot of the UAS will be an Airline Transport, Commercial, or Private certified pilot and will hold at 

least a valid third class medical.

-Each pilot of the UAS will have logged training for multirotor UAS flight consisting of takeoff and 

landing, emergency and evasive actions, and scenario based mission training.

-Each PIC will maintain currency required as applicable.
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Description of intended UAS Operations

Brasfield and Gorrie L.L.C. intend to use the Inspire within the applicable Federal Aviation Regulations 

while accomplishing our desired mission goal of jobsite survey, photography, and inspections. 

Operations will be conducted in uncontrolled airspace 500 feet AGL and below and outside a 5 nautical 

mile radius of any airport reference point. If any mission requires operation within that 5nm radius, a 

letter of agreement will be obtained from the airport’s management, and the operation will be 

conducted in accordance with a Notice to Airman as required by the Certificate Of Authorization. All 

flights will be conducted under specific operating limitations:

1. Operations authorized by this grant of exemption are limited to the DJI Inspire 1 when 

weighing less than 55 pounds including payload. Proposed operations of any other aircraft will require a 

new petition or a petition to amend this exemption. 

2. Operations for the purpose of closed-set motion picture and television filming are not 

permitted. 

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The 

exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 

87 knot speed restriction. In no case will the UA be operated at airspeeds greater than the maximum UA 

operating airspeed recommended by the aircraft manufacturer. 

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). 

Altitude must be reported in feet AGL. 

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires 

the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified 

on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license. 

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual 

line of sight (VLOS) of the PIC and VO at all times. The VO may be used to satisfy the VLOS requirement 

as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicate 

verbally at all times; electronic messaging or texting is not permitted during flight operations. The PIC 

must be designated before the flight and cannot transfer his or her designation for the duration of the 

flight. The PIC must ensure that the VO can perform the duties required of the VO. 

7. This exemption and all documents needed to operate the UAS and conduct its operations in 

accordance with the conditions and limitations stated in this grant of exemption, are hereinafter 

referred to as the operating documents. The operating documents must be accessible during UAS 

operations and made available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations in this exemption and the procedures outlined in the operating documents, 

the conditions and limitations herein take precedence and must be followed. Otherwise, the operator 

must follow the procedures as outlined in its operating documents. The operator may update or revise 
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its operating documents. It is the operator’s responsibility to track such revisions and present updated 

and revised documents to the Administrator or any law enforcement official upon request. The operator 

must also present updated and revised documents if it petitions for extension or amendment to this 

grant of exemption. If the operator determines that any update or revision would affect the basis upon 

which the FAA granted this exemption, then the operator must petition for an amendment to its grant 

of exemption. The FAA’s UAS Integration Office (AFS−80) may be contacted if questions arise regarding 

updates or revisions to the operating documents. 

8. Any UAS that has undergone maintenance or alterations that affect the UAS operation or 

flight characteristics, e.g. replacement of a flight critical component, must undergo a functional test 

flight prior to conducting further operations under this exemption. Functional test flights may only be 

conducted by a PIC with a VO and must remain at least 500 feet from other people. The functional test 

flight must be conducted in such a manner so as to not pose an undue hazard to persons and property. 

9. The operator is responsible for maintaining and inspecting the UAS to ensure that it is in a 

condition for safe operation. 

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in 

a condition for safe flight. The pre-flight inspection must account for all potential discrepancies, e.g. 

inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe 

operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has 

been performed and the UAS is found to be in a condition for safe flight. 

11. The operator must follow the UAS manufacturer’s maintenance, overhaul, replacement, 

inspection, and life limit requirements for the aircraft and aircraft components. 

12. Each UAS operated under this exemption must comply with all manufacturer safety 

bulletins. 

13. Under this grant of exemption, a PIC must hold either an airline transport, commercial, 

private, recreational, or sport pilot certificate. The PIC must also hold a current FAA airman medical 

certificate or a valid U.S. driver’s license issued by a state, the District of Columbia, Puerto Rico, a 

territory, a possession, or the Federal government. The PIC must also meet the flight review 

requirements specified in 14 CFR § 61.56 in an aircraft in which the PIC is rated on his or her pilot 

certificate. 

14. The operator may not permit any PIC to operate unless the PIC demonstrates the ability to 

safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption, 

including evasive and emergency maneuvers and maintaining appropriate distances from persons, 

vessels, vehicles and structures. PIC qualification flight hours and currency must be logged in a manner 

consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs 

(training, proficiency, and experience-building) and determining the PIC’s ability to safely operate the 
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UAS in a manner consistent with how the UAS will be operated under this exemption are permitted 

under the terms of this exemption. However, training operations may only be conducted during 

dedicated training sessions. During training, proficiency, and experience-building flights, all persons not 

essential for flight operations are considered nonparticipants, and the PIC must operate the UA with 

appropriate distance from nonparticipants in accordance with 14 CFR § 91.119. 

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). Flights under special visual 

flight rules (SVFR) are not authorized. 

16. The UA may not operate within 5 nautical miles of an airport reference point (ARP) as 

denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the 

center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter 

of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the 

exemption holder. The letter of agreement with the airport management must be made available to the 

Administrator or any law enforcement official upon request. 

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the PIC. 

18. If the UAS loses communications or loses its GPS signal, the UA must return to a predetermined location within the private or controlled-access property. 

19. The PIC must abort the flight in the event of unpredicted obstacles or emergencies. 

20. The PIC is prohibited from beginning a flight unless (considering wind and forecast weather 

conditions) there is enough available power for the UA to conduct the intended operation and to 

operate after that for at least five minutes or with the reserve power recommended by the 

manufacturer if greater. 

21. Air Traffic Organization (ATO) Certificate of Waiver or Authorization (COA). All operations 

shall be conducted in accordance with an ATO-issued COA. The exemption holder may apply for a new 

or amended COA if it intends to conduct operations that cannot be conducted under the terms of the 

attached COA. 

22. All aircraft operated in accordance with this exemption must be identified by serial number, 

registered in accordance with 14 CFR part 47, and have identification (N−Number) markings in 

accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable. 

23. Documents used by the operator to ensure the safe operation and flight of the UAS and any 

documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground 

Control Station of the UAS any time the aircraft is operating. These documents must be made available 

to the Administrator or any law enforcement official upon request. 
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24. The UA must remain clear and give way to all manned aviation operations and activities at all 

times. 

25. The UAS may not be operated by the PIC from any moving device or vehicle. 

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons from the UA 

and/or debris in the event of an accident. The operator must ensure that nonparticipating persons 

remain under such protection. If a situation arises where nonparticipating persons leave such protection 

and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the 

safety of nonparticipating persons; and 

b. The owner/controller of any vessels, vehicles or structures has granted permission for operating 

closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those 

objects and determined that it does not present an undue hazard. 

The PIC, VO, operator trainees or essential persons are not considered nonparticipating persons under 

this exemption. 

27. All operations shall be conducted over private or controlled-access property with permission 

from the property owner/controller or authorized representative. Permission from property 

owner/controller or authorized representative will be obtained for each flight to be conducted. 

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration 

Office (AFS−80) within 24 hours. Accidents must be reported to the National Transportation Safety 

Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov. 

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations 

must comply with all applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.
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Benefits of the utilization of UAS

Brasfield & Gorrie stands to enhance the safety of our employees by reducing the exposure to risk. 

External building inspection above 6’ would no longer require a person to assume some risk by putting 

themselves in a position relative to the structure that is not inherently safe. Aerial inspection and 

photography done by full sized rotorcraft can be minimized, thus lowering any additional strain on the 

Air Traffic Control system as well as lowering emissions produced by those vehicles. From an aviation 

community enhancement prospective, the process of training an employee on Private Pilot curriculum 

may spur on an interest in general aviation and add to the general public’s favorable vision of aviation.

DJI Inspire 1 specifications

Aircraft

Model - T600

Weight (Battery Included) - 2935 g

Hovering Accuracy (GPS mode) - Vertical: 0.5 m, Horizontal: 2.5 m

Max Angular Velocity - Pitch: 300°/s, Yaw: 150°/s

Max Tilt Angle - 35°

Max Ascent Speed - 5 m/s

Max Descent Speed - 4 m/s

Max Speed - 22 m/s (ATTI mode, no wind)

Max Flight Altitude - 4500 m

Max Wind Speed Resistance - 10 m/s

Max Flight Time - Approximately 18 minutes

Motor Model - DJI 3510

Propeller Model - DJI 1345

Indoor Hovering - Enabled by default

Operating Temperature Range - -10° to 40° C

Diagonal Distance - 559 to 581 mm

Dimensions - 438x451x301 mm

Gimbal

Model - ZENMUSE X3

Output Power (with camera) - Static: 9 W, In Motion: 11 W

Operating Current - Station: 750 mA, Motion: 900 mA
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Angular Vibration Range - ±0.03°

Mounting - Detachable

Controllable Range - Pitch: -90° to +30°, Pan: ±320°

Mechanical Range - Pitch: -125° to +45°, Pan: ±330°

Max Controllable Speed - Pitch: 120°/s, Pan: 180°/s

Camera

Name - X3

Model - FC350

Total Pixels - 12.76M

Effective Pixels - 12.4M

Image Max Size - 4000x3000

ISO Range - 100-3200 (video) - 100-1600 (photo)

Electronic Shutter Speed - 8s - 1/8000s

FOV (Field of View) - 94°

CMOS - Sony EXMOR 1/2.3”

Lens - 20mm (35mm format equivalent)f/2.8 focus at ∞, 9 Elements in 9 groups, Antidistortion 

Still Photography Modes - Single shoot

Burst shooting: 3/5/7 frames

Auto Exposure Bracketing (AEB): 3/5 bracketed frames at 0.7EV Bias

Time-lapse

Video Recording Modes - UHD (4K): 4096x2160p24/25, 3840x2160p24/25/30

FHD: 1920x1080p24/25/30/48/50/60

HD: 1280x720p24/25/30/48/50/60

Max Bitrate of Video Storage - 60 Mbps

Supported File Formats -FAT32/exFAT

Photo: JPEG, DNG

Video: MP4/MOV (MPEG-4 AVC/H.264)

Supported SD Card Types - Micro SD

Max capacity: 64 GB. Class 10 or UHS-1 rating required.

Operating Temperature Range - 0° to 40° C

Remote Name - C1
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Controller Operating Frequency -922.7~927.7 MHz (Japan Only)

5.725~5.825 GHz

2.400~2.483 GHz

Transmitting Distance (outdoor and unobstructed) - 2 km

EIRP - 10dBm@900m, 13dBm@5.8G, 20dBm@2.4G

Video Output Port - USB, mini-HDMI

Power Supply - Built-in battery

Charging - DJI charger

Dual User Capability - Host-and-Slave connection

Mobile Device Holder - Tablet or Phone

Max Mobile Device Width - 170m

Output Power - 9 W

Operating Temperature Range - -10° to 40° C

Storage Temperature Range - Less than 3 months: -20° to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range - 0-40° C

Battery - 6000 mAh LiPo 2S

Charger

Model - A14-100P1A

Voltage - 26.3 V

Rated Power - 100 W

Battery 

(Standard)

Name - Intelligent Flight Battery

Model - TB47

Capacity - 4500 mAh

Voltage - 22.2 V

Battery Type - LiPo 6S High voltage battery

Energy - 99.9 Wh

Net Weight - 570 g

Operating Temperature Range - -10° to 40° C
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Storage Temperature Range - Less than 3 months: -20° to 45° C

More than 3 months: 22° C to 28° C

Charging Temperature Range - 0° to 40° C

Max Charging Power - 180 W

Battery 

(Optional)

Name - Intelligent Flight Battery

Model - TB48

Capacity - 5700 mAh

Voltage - 22.8 V

Battery Type - LiPo 6S

Energy - 129.96 Wh

Net Weight - 670 g

Operating Temperature Range - -10° to 40° C

Storage Temperature Range - Less than 3 months: -20 to 45° C

More than 3 months: 22° to 28° C

Charging Temperature Range - 0° to 40° C

Max Charging Power - 180 W

Vision 

Positioning

Velocity Range - Below 8 m/s (2 m above ground)

Altitude Range - 5-500 cm

Operating Environment - Brightly lit (lux > 15) patterned surfaces

Operating Range - 0-250 cm
26

Summary for Federal Register Publication

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal

Register should the FAA determine that publication is needed.

Petitioner: Brasfield & Gorrie L.L.C.

Sections of 14 C.F.R. Affected:

14 C.F.R. §61.23(a) and (c)

14 C.F.R. §61.113(a)

14 C.F.R. §91.7(a)

14 C.F.R. §91.119(c)

14 C.F.R. §91.121

14 C.F.R. §91.151(a)(1)

14 C.F.R. §91.405(a)

14 C.F.R. §91.407(a)(1)

14 C.F.R. §91.409(a)(1) and (2)

14 C.F.R. §91.417(a) and (b)

Description of Relief Sought: Petitioner seeks relief from the requirements of the above parts to the CFRs 

to conduct UAS operations over private and publicly owned or controlled land, solely during daylight 

hours and in visual meteorological conditions, to conduct surveys, inspections, and photography of 

Brasfield & Gorrie jobsites, Brasfield & Gorrie owned property, and controlled prospective jobsites. In 

general, the UAS mission will be limited to line of sight with a max altitude of 400’ AGL. The flight crew 

will consist of a pilot in command and a visual observer.